# Ozone State Implementation Plan (SIP) Revision

Reasonably Available Control Technol ogy (RACT) as Applicable to the

8-Hour Ozone Standard

Sacramento Metropolitan Air Qu ality Management District

October 26, 2006

# SMAQMD Ozone SIP Revision

RACT for the 8-Hour Ozone Standard
October 26, 2006 Page 1

Background

This document constitutes a revision to the Ozone State Implementation Plan (SIP) for the Sacramento Air Quality Management District (SMAQMD). The U.S. Environmental Protection Agency (EPA) published the final Phase 2 Rule to implement the 8-hour ozone air quality standard on November 29, 2005 (70 FR 71611). Among the requirements of the Phase 2 Rule, a new section was added to the Code of Federal Regulations (40 CFR 51.912) that requires the SMAQMD to submit a revision to the SIP that meets the Reasonably Available Control Technology (RACT) requirements for VOC and NOx in accordance with Sections 182(b)(2) and 182(f) of the federal Clean Air Act for:

• Each category of VOC sources that is covered by a Control Technique Guideline (CTG) document issued by EPA; and

• All major stationary sources of VOC and/or NOx.

EPA’s designations and classifications for the 8-hour ozone standard were published on April 30, 2004 (69 FR 23857) and became effective on June 15, 2004. The Sacramento Metropolitan

Area was classified as a serious nonattainment area, with a deadline of 2013 to attain the standard. The major source emissions threshold fo r areas classified as serious is 50 tons per year of either VOC or NOx.

This SIP revision is based on an analysis performed by SMAQMD staff in accordance with EPA guidance. The analysis is presented in the Staff Report for Analysis of Reasonably Available Control Technology for the 8-Hour Ozone State Implementation Plan (RACT SIP) , SMAQMD, September 26, 2006.

Negative Declarations

The SMAQMD has reviewed its records for permitted sources, the enforcement program for unpermitted sources, and telephone yellow pages and has determined that there are no stationary sources or emitting facilities for the following CTG categories. In addition, the SMAQMD does not anticipate these sources in the future.

Source Category CTG Document Title Document

Number Automobile Coating Control of Volatile Organic Emissions from Existing Stationary Sources, Volume II: Surface Coating ofCans, Coils, Paper, Fabrics, Automobiles, and LightDuty Trucks EPA-450/2-77-008

Dry Cleaning (Petroleum Solvent) Control of Volatile Organic Compound Emissions from Large Petroleum Dry Cleaners EPA-450/3-82-009

Graphic Arts (Rotogravure) Control of Volatile Organic Emissions from Existing Stationary Sources, Volu me VIII: Graphic Arts – Rotogravure and Flexography EPA-450/2-78-033

Large Appliance Coating Control of Volatile Organic Emissions from Existing Stationary Sources, Volume V: Surface Coating of Large Appliances EPA-450/2-77-034

Magnetic Wire Coating Control of Volatile Or ganic Emissions from Existing EPA-450/2-77-033

# SMAQMD Ozone SIP Revision

RACT for the 8-Hour Ozone Standard
October 26, 2006 Page 2

Source Category CTG Document Title Document

Number Stationary Sources, Volume IV: Surface Coating for Insulation of Magnetic Wire Metal Coil Coating Control of Volatile Organic Emissions from Existing Stationary Sources, Volume II: Surface Coating ofCans, Coils, Paper, Fabrics, Automobiles, and LightDuty Trucks EPA-450/2-77-008

Natural Gas/Gasoline Processing Control of Volatile Organic Compound Equipment Leaks from Natural Gas/Gasoline Processing Plants EPA-450/2-83-007

Paper and Fabric Coating Control of Volatile Organic Emissions from Existing Stationary Sources, Volume II: Surface Coating ofCans, Coils, Paper, Fabrics, Automobiles, and LightDuty Trucks EPA-450/2-77-008

Resin Manufacturing (High-Density Polyethylene, Polypropylene, and Polystyrene) Control of Volatile Organic Compound Emissions from Manufacture of High-Density Polyethylene, Polypropylene, and Polystyrene Resins EPA-450/3-83-008

Refineries Control of Refinery Vacuum Producing Systems, Wastewater Separator s and Process Unit

Turnarounds

Control of Volatile Organic Compound Leaks from Petroleum Refinery Equipment EPA-450/2-77-025

EPA-450/2-78-036

Rubber Tire Manufacturing Control of Volatile Organic Emissions from

Manufacture of Pneumatic Rubber Tires EPA-450/2-78-030

Ship Coating Control Techniques Guidelines for Shipbuilding and Ship Repair Operations (Surface Coating) 61 FR 44050

Wood Coating (Flat Wood Paneling) Control of Volatile Organic Emissions from Existing Stationary Sources, Volume VII: Factory Surface Coating of Flat Wood Paneling EPA-450/2-78-032



# RACT Determination for CTG Categories

The SMAQMD has performed an analysis of District rules and has determined that the District has implemented RACT for all CTG categories for which there are existing sources. The CTG categories and the applicable District rules are shown in the following table.SMAQMD Ozone SIP RevisionRACT for the 8-Hour Ozone StandardOctober 26, 2006Page 3SourceCategoryCTG Document TitleCTG DocumentNumberSMAQMDRule No.(Most RecentAmendment)SIP StatusAerospaceManufacturingControl of Volatile OrganicCompound Emissions fromCoating Operations atAerospace Manufacturingand Rework OperationsEPA-453/R-97-004 456 (7/23/98) Adopted 9/5/96; Approved 11/9/98Cutback Asphalt Control of Volatile OrganicCompounds from Use ofCutback AsphaltEPA-450/2-77-037 453 (8/31/82) Adopted 8/31/82; Approved 1/24/85GasolineService StationsDesign Criteria for Stage IVapor Control Systems,Gasoline Service Stations,November 1975None 448 (2/2/95)449 (9/26/02)448: Adopted 2/2/95;Approved 1/23/96449: Adopted 9/26/02; Approved 3/24/03Gasoline TankTrucks and BulkPlants1. Control of Hydrocarbonsfrom Tank Truck GasolineLoading Terminals2. Control of Volatile OrganicEmissions from GasolineBulk Plants3. Control of Volatile OrganicCompound Leaks fromGasoline Tank Trucks andVapor Collection SystemsEPA-450/2-77-026EPA-450/2-77-035EPA-450/2-78-051447 (4/2/98)448 (2/2/95)447: Adopted 4/2/98;Approved 11/26/99448: Adopted 2/2/95;Approved 1/23/96Graphic Arts(Flexography)Control of Volatile OrganicEmissions from ExistingStationary Sources, VolumeVIII: Graphic Arts –Rotogravure and FlexographyEPA-450/2-78-033 450 (3/23/00) Adopted 12/5/96; Approved 11/13/98SMAQMD Ozone SIP RevisionRACT for the 8-Hour Ozone StandardOctober 26, 2006Page 4SourceCategoryCTG Document TitleCTG DocumentNumberSMAQMDRule No.(Most RecentAmendment)SIP StatusMetal CanCoatingControl of Volatile OrganicEmissions from ExistingStationary Sources, VolumeII: Surface Coating of Cans,Coils, Paper, Fabrics,Automobiles, and Light-DutyTrucksEPA-450/2-77-008 452 (9/5/96) Adopted 9/5/96; Approved 11/9/98Metal FurnitureCoatingControl of Volatile OrganicEmissions from ExistingStationary Sources, VolumeIII: Surface Coating of MetalFurnitureEPA-450/2-77-032 451 (10/2/97) Adopted 11/29/83; Approved 1/24/85Adopted 9/5/96; No EPA ActionMetal Parts andProductsCoatingControl of Volatile OrganicEmissions from ExistingStationary Sources, VolumeVI: Surface Coating ofMiscellaneous Metal Partsand ProductsEPA-450/2-78-015 451 (10/2/97) Adopted 11/29/83; Approved 1/24/85Adopted 9/5/96; No EPA ActionPetroleumLiquid StorageTanks1. Control of Volatile OrganicEmissions from Storage ofPetroleum Liquids inFixed-Roof Tanks2. Control of Volatile OrganicEmissions from PetroleumLiquid Storage in ExternalFloating Roof TanksEPA-450/2-77-036EPA-450/2-78-047446 (11/16/93) Adopted 11/16/93; Approved 9/16/94PharmaceuticalProductsManufacturingControl of Volatile OrganicEmissions from Manufactureof SynthesizedPharmaceutical ProductsEPA-450/2-78-029 455 (9/5/96) Adopted 11/29/83; Approved 1/24/85Adopted 9/5/96; No EPA ActionSMAQMD Ozone SIP RevisionRACT for the 8-Hour Ozone StandardOctober 26, 2006Page 5SourceCategoryCTG Document TitleCTG DocumentNumberSMAQMDRule No.(Most RecentAmendment)SIP StatusSolventCleaning(Degreasers)Control of Volatile OrganicEmissions from Solvent MetalCleaningEPA-450/2-77-022 454 (5/23/02) Adopted 4/3/97; Approved 4/2/99SyntheticOrganicChemicalManufacturing1. Control of Volatile OrganicCompound Leaks fromSynthetic OrganicChemical and PolymerManufacturing Equipment2. Control of Volatile OrganicCompound Emissions fromAir Oxidation Processes inSynthetic OrganicChemical ManufacturingIndustry3. Control of Volatile OrganicCompound Emissions fromReactor Processes andDistillation OperationsProcesses in the SyntheticOrganic ChemicalManufacturing IndustryEPA-450/3-83-006EPA-450/3-84-015EPA-450/4-91-031443 (9/5/96)464 (7/23/98)443: Adopted 9/5/96;Approved 11/9/98464: Adopted 7/23/98; Approved 4/19/00Wood FurnitureCoatingControl of Volatile OrganicCompound Emissions fromWood FurnitureManufacturing OperationsEPA-453/R-96-007 463 (7/23/98)Adopted 12/5/96; No EPA Action

# SMAQMD Ozone SIP Revision

RACT for the 8-Hour Ozone Standard
October 26, 2006 Page 6

RACT Determination for Major Sources of VOC or NOx

The SMAQMD has performed an analysis of major s ources of VOC or NOx within the District and has determined that the requirements of RACT have been satisfied for all major sources. The list of major sources within the District is shown in the following table.

Major Source Major Pollutant(s) Aerojet VOC, NOx Campbell Soup NOx Carson Energy NOx

Chevron VOC

Kiefer Landfill VOC, NOx

Procter and Gamble VOC Sacramento Cogeneration Authority NOx Santa Fe Pacific Pipeline VOC

SMUD Cosumnes Power Plant NOx University of California, Davis Medical Center NOx



# One major source, the Kiefer Landfill, has a landfill gas flare for which the emissions of NOx are not limited by a District rule. The portions of Permit to Operate 17359 that limit the flare to NOx emissions of 0.06 lb/mmBtu, and the associated testing and recordkeeping requirements, are included in this SIP revision to satisfy the RACT requirements, as described in the following

section.

Inclusion of Permit to Operate 17359 for the Kiefer Landfill Flare

Permit Description

The permit being submitted for inclusion in the SIP is the local District permit for the air pollution control landfill gas flare (currently P/O 17359). Permit conditions that have been left blank do not pertain to the NOx 0.06 lbs/mmBtu limit on the flare permit. A copy of the permit is attached

to this document.

Additional Conditions to be Included in the Permit :

The following conditions will be added to the permit at its next update.

Specific Conditions to Be Added:

RACT DETERMINATION

28. This permit incorporates a Reasonably Available Control Technology (RACT) determination as required by Title I provisions of the Clean Air Act Amendments.

29. The expiration date shown on this permit is for state purposes. For Federal enforcement purposes the RACT provisions of this permit that are approved by U.S. Environmental Protection Agency (EPA) shall remain in effect as part of the

# SMAQMD Ozone SIP Revision

RACT for the 8-Hour Ozone Standard
October 26, 2006 Page 7

State Implementation Plan (SIP) until replaced pursuant to 40 CFR 51 and approved by the EPA.

Specific Conditions to be Amended:

The following will be added to existing Condition 16 under the “At all times” column. 16.F. Records of sources test plans and results to determine compliance with the NOx limit in Condition #6 shall be maintained for a minimum of 5 years.

The following will be added to Condition #27. 27.F. Compliance with the NOX limit shall be determined using one of the following

source test methods: 1) ARB Method 100; 2) EPA Method 7E; or 3) Any other method approved by the U.S. Environmental Protection Agency, the California Air Resources Board, and the Air Pollution Control

Officer.